Privacy Policy

Last updated: March 2026

Finsibility ("we", "our", "us") respects your privacy. This Policy explains how we collect, use, and safeguard your information when you use the Finsibility mobile application, website (if applicable), related services, and communications with us.

1. Information we collect

1.1 Account Data

1.2 Financial Data

1.3 Usage Data

We collect analytics data to improve the Service, including:

Most usage analytics data is aggregated and anonymized. However, certain operational and billing-related logs (such as transaction processing logs, subscription lifecycle events, and error diagnostics) may contain user identifiers to enable billing dispute resolution, fraud detection, customer support, and system debugging. These operational logs are retained for 30 days (90 days for crash diagnostics) and are used solely for the purposes described in Section 2 of this Policy.

1.4 Operational and Billing Logs

In addition to anonymized analytics, we maintain operational logs that may include:

These logs are necessary for processing transactions, managing subscriptions, resolving billing disputes, preventing fraud, and ensuring service reliability as described in Sections 2.1 and 2.2. Operational logs are retained for 30 days (90 days for crash diagnostics) and are not shared with third parties except as described in Section 3.

2. How we use data

2.1 Service Provision

We use your data to:

2.2 Legal Basis for Processing

We process your personal data based on:

2.3 Financial Data Usage

Important: Financial data you provide (including account balances, transactions, and financial model parameters) is used solely to:

We do NOT use your financial data to:

All projections and forecasts generated by the Service — whether by you, by our AI analysis tools, or by community contributors — are based on assumptions and mathematical models. They are not guarantees of future performance. No one can predict the future. Where users share models or analyses through the community feed, such sharing is between peers and does not constitute advisory services from Finsibility. Please refer to our Terms of Service for important disclaimers regarding financial projections and the limitations of our Service.

3. Data sharing

3.1 We Do Not Sell Your Personal Data

We do not sell, rent, lease, or trade your personal information or individual financial data to third parties. We do not share your personal data with advertisers or marketing partners for their own purposes.

We may use aggregated, anonymized data — which cannot be used to identify any individual user — for purposes such as understanding usage trends, improving the Service, or sharing general insights. This aggregated data does not include your name, account details, or any information that could identify you.

3.2 Limited Sharing

We share your data only in the following limited circumstances:

Service Providers: We share data with infrastructure and service providers who help us operate the Service, including:

The specific providers we use may change over time. We will update this list when material changes occur. Our use of these providers is governed by their standard terms of service, which include data handling and usage provisions. For information about a provider's own security practices and data handling commitments, please refer to their published terms and trust documentation.

Legal Requirements: We may disclose your data if required by law, court order, government regulation, or to:

Business Transfers: In the event of a merger, acquisition, sale of assets, or bankruptcy, your data may be transferred to the acquiring entity. We will make reasonable efforts to ensure the acquiring party is informed of the commitments made in this Policy and will notify you before your data is transferred or becomes subject to a different privacy policy.

With Your Consent: We may share your data with third parties when you have given us explicit consent to do so.

4. Security

4.1 Data Protection Measures

Production Environment:

We implement industry-standard security measures to protect your data:

Beta and Pre-Production Environments:

During beta testing and pre-production phases, data is encrypted both in transit and at rest. However, pre-production environments may use less restrictive access controls and data isolation practices than production. We recommend exercising caution with highly sensitive financial information during beta testing.

4.2 Data Breach Notification

In the event of a data breach that may affect your personal information, we will notify you and relevant authorities as required by applicable law, typically within 72 hours of becoming aware of the breach. We will provide information about the nature of the breach, the data affected, and steps we are taking to address it.

4.3 Your Role in Security

You play an important role in keeping your data secure:

5. Your choices and rights

5.1 Data Access and Portability

You have the right to access, review, and export your personal data. You can request a copy of your data via Account → Security → Export Data or by contacting us at privacy@finsibility.com.

5.2 Data Deletion

You can request deletion of your account and all associated data at any time via Account → Security → Delete Account or by contacting us at privacy@finsibility.com. Upon receiving your request, we will promptly delete or anonymize your personal data, except where we are required to retain it by:

We will notify you if we are unable to delete certain data due to legal requirements.

5.3 Data Correction

You can update your account information at any time through your account settings. If you need assistance correcting data, contact us at privacy@finsibility.com.

5.4 Communications

We do not send marketing emails. Communications you receive from Finsibility are limited to essential service-related messages such as security alerts, account updates, and transactional notifications. You can manage push notification preferences under Account → Preferences → Notifications.

5.5 California Privacy Rights (CCPA)

If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA), including:

To exercise these rights, contact us at privacy@finsibility.com. We will respond within 30 days.

5.6 Other U.S. State Privacy Rights

If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, or any other U.S. state with a comprehensive consumer privacy law, you may have similar rights to those described in Section 5.5 above, including the right to access, delete, and correct your personal data, and the right to opt out of the sale of personal information (which we do not engage in). To exercise any privacy rights under applicable state law, contact us at privacy@finsibility.com. We will respond within the timeframe required by your state's applicable law.

Future Expansion: Finsibility is currently available in the United States. As we expand to other jurisdictions, we will update this Privacy Policy to include applicable privacy rights, including GDPR rights for European Economic Area (EEA) residents when we launch in those regions.

6. Children and Age Restrictions

Finsibility is not directed to children under 18 years of age. You must be at least 18 years old to use the Service. We do not knowingly collect personal information from individuals under 18. If we become aware that we have collected personal information from someone under 18, we will delete that information immediately. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@finsibility.com.

COPPA Compliance: While the Children's Online Privacy Protection Act (COPPA) applies to children under 13, our Service requires users to be 18 or older. We do not knowingly collect information from anyone under 18.

7. Data Retention

7.1 Retention Periods

We retain your personal data for as long as necessary to provide the Service and fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law:

7.2 Data Deletion

When you delete your account, we will promptly delete or anonymize your personal data, except where retention is required by law or for legitimate business purposes.

8. Data Location and International Transfers

Current Service Area: Finsibility is currently available in the United States. Your data is stored and processed in the United States.

Service Provider Locations: Our service providers may process your data in the United States and other countries where they operate. Each provider's handling of your data is governed by their own terms of service and privacy policies. For information about a specific provider's data practices, please refer to their published terms.

Future Expansion: As we expand to other jurisdictions, we will implement appropriate safeguards for international data transfers, including standard contractual clauses and other mechanisms required by applicable law. We will update this Privacy Policy to reflect any changes in data processing locations or transfer mechanisms.

9. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements.

9.1 Material Changes

A "material change" is one that meaningfully affects your privacy rights or how we handle your data, including but not limited to:

We will notify you of material changes by:

Material changes will take effect 30 days after posting. Your continued use of the Service after the effective date constitutes acceptance of the updated Policy. If you do not agree to the changes, you should stop using the Service and delete your account.

9.2 Non-Material Changes

Non-material changes — such as fixing typos, clarifying existing language without changing its substance, updating a service provider's name when the data flow is unchanged, or reorganizing sections for readability — take effect immediately upon posting and do not require advance notice.

10. AI & Machine Learning Privacy Protections

Our Commitment

Finsibility uses AI to power a range of AI-assisted experiences, including intelligent navigation, workflow automation, full and partial form filling, analytical (non-advisory) narration, and comparative analysis. All AI-powered features are gated behind explicit user consent within the app — no AI processing occurs until you actively choose to use an AI feature. We have implemented technical safeguards to keep your identity and personal information separate from AI interactions. Finsibility does not provide portfolio optimization, portfolio rebalancing, or financial advisory services. We are a platform that enables peer-driven financial analysis and comparison.

What We Send to AI Providers

Our AI-powered analysis features send sanitized financial parameters to AI service providers:

Information sent to AI:

Information not sent to AI:

How We Protect Your Data

We apply multiple layers of sanitization on both your device and our servers:

1. Client-side name replacement – Your device replaces identifiable item names with category-based labels before data leaves your phone

2. Server-side PII filtering – Our servers apply pattern-based filtering to catch and remove identity-linked fields before contacting any AI service

3. Identifier anonymization – Database record IDs are replaced with anonymous sequential references before being sent to AI and remapped back in responses

4. Data minimization – Empty and unnecessary fields are stripped from payloads before transmission

5. Date conversion – Financial date fields within model data are converted to relative offsets. Note: some contextual dates (such as graph viewport boundaries used for time-range analysis) may be sent as-is to enable accurate results

6. Audit logging – AI requests are logged with privacy compliance verdicts

Bulk Document Import (Creator Accounts)

Finsibility offers a bulk document import feature that allows Creator account holders to upload spreadsheets, PDFs, images, and other documents for AI-powered extraction of financial items.

Important: Unlike the standard AI-assisted features described above, the bulk document import sends the full, unsanitized contents of your uploaded document to our AI service provider. This is necessary because the AI must read the raw document to identify and extract financial items from arbitrary formats and layouts.

What is sent to AI during bulk import:

What is NOT sent to AI during bulk import:

Safeguards:

1. Creator-only access — Bulk document import is restricted to Creator accounts. Consumer accounts must add items manually or use the standard AI-assisted features, which apply privacy-preserving sanitization before any data is sent to AI providers (see "How We Protect Your Data" and "AI Voice Narration" above for details on the specific safeguards applied to each provider)

2. Explicit consent — Before any document is analyzed, you are presented with a clear disclosure explaining that the full file contents will be sent to the AI service, and you must explicitly acknowledge this before proceeding

3. Provider data handling — Document content is sent for processing and is subject to the AI provider's own data handling and retention policies. We do not control how long providers may retain data for their operational purposes (such as abuse monitoring). Please refer to the provider's published terms for details

4. Local extraction — For images, OCR text recognition is performed on your device before the extracted text is sent to the AI service

Supported formats: CSV, TSV, TXT, Excel (.xlsx, .xls), PDF, and images (JPG, JPEG, PNG, HEIC via on-device OCR).

We strongly recommend that you review your documents for sensitive personal information before uploading them for bulk import. If your document contains data you do not wish to share with an AI service provider, you should use the standard manual entry or AI-assisted features, which apply full sanitization.

AI Voice Narration

Finsibility includes an optional AI voice feature that provides spoken narration of analysis results using a third-party text-to-speech service.

Voice narration requires your explicit consent. You can enable or disable it at any time from the Voice Assistant settings. When disabled, no data of any kind is transmitted to the voice provider.

What is sent to the voice service:

What we take steps to prevent from being sent:

Note that not all narration paths apply the same level of sanitization. User-created group names and certain descriptive text may pass through to the voice service. Our backend performs a PII scan on every voice request and blocks transmission if structured PII (emails, database IDs, phone numbers) is detected, but this scan does not catch all forms of personal information that may be embedded in user-created names or text. The voice provider's handling and retention of narration data is governed by their own terms of service.

Our Security Practices

Your Control

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11. Advertisements

11.1 Right to Display Advertisements

We reserve the right to display advertisements on our platform. Advertisements may appear within the Service interface, and we may partner with third-party advertising networks to serve ads. If we display advertisements, they will be clearly identified as such.

11.2 Advertisements and Your Data

Important: Even if we display advertisements, we will not sell your personal data to advertisers. Advertisements may be targeted based on:

If we use third-party advertising partners, we will disclose them in this policy and provide you with the ability to opt out of personalized advertising. We will not share your financial data or account details with advertisers. We comply with applicable opt-out requirements, including Apple's App Tracking Transparency framework and any "Do Not Sell or Share" rights under applicable law.

11.3 Ad-Free Options

We do not currently display advertisements. If advertisements are introduced in the future, premium subscription tiers may include an ad-free experience. We will update this policy and notify users in advance of any such changes.

12. Local Storage and Device Data

12.1 Data Stored on Your Device

Finsibility is a mobile application and does not use browser cookies. We store data locally on your device to operate the Service, including:

12.2 Device Identifiers

We may use anonymized device identifiers for analytics purposes (as described in Section 1.3). We do not use device identifiers for advertising or to track you across other applications.

13. Third-Party Links

The Service may contain links to third-party websites or services. We are not responsible for the privacy practices, cybersecurity practices, or content of these third parties.

In particular, the Community Feed screen includes an "Action" button on posts that may direct you to external websites outside of the Finsibility app. Much like searching for a financial product through any internet-based link-redirecting service, navigating to external links carries inherent risks. These external websites may have security practices, privacy practices, or content that are outside of Finsibility's control and may not meet the same standards we uphold within the Service. External links could potentially lead to websites that are deceptive, fraudulent, or compromised — including sites designed to promote misleading financial schemes or steal personal and financial information. By navigating to any external link, you acknowledge that you are leaving the Finsibility app and that your interaction with the third-party site is governed solely by that site's own policies.

Finsibility is committed to investing in content moderation and ensuring that creators with strong reputations receive greater visibility in the Community Feed. However, we strongly encourage you to exercise caution and due diligence before clicking on or navigating to any external link. Be wary of offers that seem too good to be true, requests for sensitive financial information, or sites that appear suspicious or unfamiliar. Always review the destination URL, the third party's privacy policy, and their security practices before providing any personal information or engaging with their content.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: privacy@finsibility.com

For California privacy rights (CCPA): privacy@finsibility.com

We will respond to your inquiry within 30 days.